Thread Subject: Re: FW: TIARequestforGuidance(TEITACDiscussionsof2006.11.13)

From: John Combs (jcombs)
Date: Wed, Nov 15 2006 5:50 PM

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I stand corrected, cordless phones do need to meet FCC 68.317 Volume Control (VC).

The 1988 HAC Act didn't require (VC). The VC requirement was added in the 1996 modification of the 1988 HAC ACT, when it included the following addition to FCC Part 68:

------------------------
4. A new Section 68.6 is added as follows:
 68.6 Telephones with volume control.

As of November 1, 1998, all telephones, including cordless telephones, as
defined in Section 15.3(j) of these rules, manufactured in the United States
(other than for export) or imported for use in the United States, must have
volume control in accordance with Section 68.317 of these rules. Secure
telephones, as defined by Section 68.3 of these rules, are exempt from this
section, as are telephones used with public mobile services or private radio
services.
------------------------



Unfortunately, I was mislead by another FCC web page:
FREQUENTLY ASKED QUESTIONS REGARDING HEARING AID COMPATIBILITY AND VOLUME CONTROL HAC/VC)
http://www.fcc.gov/Bureaus/Common_Carrier/FAQ/faq_hac.html


It states:

-----------------------
Do all HAC phones sold in the U.S. also have volume control?

Not at present. The definition of hearing aid compatibility was recently expanded to include the volume control feature. Manufacturers and importers will be required to ensure that wireline telephones manufactured imported for use in the U.S. after January 1, 2000 contain a volume control feature.
-----------------------


This made me curious as to what the 2003 modification of the HAC Act actually required for wireless (cellular) phones. Here's what I found:


By the way, here's an excerpt from the 1996 modification worth noting:
http://www.fcc.gov/cgb/dro/hacrules.txt

--------------------
Hearing aid compatible: Except as used at  68.4(a)(3) and
68.414 of these rules, the terms hearing aid compatible or hearing aid
compatibility are used as defined in  68.316, unless it is specifically stated
that hearing aid compatibility volume control, as defined in  68.317, is
intended or is included in the definition.
--------------------

This means that whenever the term HAC is used in an FCC document, it *only* refers to FCC 68.316 HAC, *unless* FCC 68.317 VC is *specifically* called out.


Here's the link to the 2003 FCC Report & Order which modified the HAC Act to cover digital wireless phones:
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-168A1.doc

This document explicitly states only that digital wireless phones must meet an ANSI specification for hearing aid T-coil compatibility, and another ANSI specification to keep extraneous Radio Frequency (RF) signal levels below a limit intended to minimize RF interference with hearing aids.

So I don't believe VC is required for digital wireless (cellular) phones. Meaning, they are not required to have a minimum of 12 dB of acoustic gain from default volume.


Note: Analog wireless (cellular) phones are not mentioned because that service will be phased out in the U.S. in about a year.


- John


-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of = EMAIL ADDRESS REMOVED =
Sent: Wednesday, November 15, 2006 3:41 PM
To: TEITAC Telecommunications Subcommittee
Subject: Re: [teitac-telecom] FW: TIA RequestforGuidance(TEITACDiscussionsof2006.11.13)

The HAC Act does requie cordless phones to be HAC and have volume control Sent from my Verizon Wireless BlackBerry

-----Original Message-----
From: "John Combs (jcombs)" < = EMAIL ADDRESS REMOVED = >
Date: Wed, 15 Nov 2006 16:29:14
To:"TEITAC Telecommunications Subcommittee" < = EMAIL ADDRESS REMOVED = >
Subject: Re: [teitac-telecom] FW: TIA RequestforGuidance(TEITACDiscussionsof 2006.11.13)

Hi Jim,

You asked:

>>> John -- has Cisco ever referred to the gain issue in VPATs for its wireless handsets?  (To be clear, Cisco makes wireless handsets not for public wireless networks but for its own VoIP phone systems.)<<<

FCC HAC = Hearing Aid Compatible, i.e., it puts out a strong, uniform magnetic field that is picked up by T-coil hearing aids.

FCC VC = Volume Control (the 12 dB minimum audio gain requirement)


Cisco makes one wireless handset -- the 7920 WiFi phone --, which only works via VoIP for WiFi frequencies (802.11), with our IP-PBX called Cisco Call Manager.

The 7920 WiFi phone is HAC, i.e., it works with T-coil hearing aids.  It does not have high volume boost, I'm not sure what it actually is, but I am sure it's less than 12 dB, due to battery life considerations.


Here's some background on FCC-speak for various categories of radio frequency handsets:

* Cordless -- this is the FCC's term for a radio frequency handset that communicates only with a private a base station, and the base station plugs into a normal analog PSTN phone line.  Cordless handsets must be HAC, but are NOT required to meet the FCC VC gain requirement, due to battery life considerations.

* Wireless -- this is the FCC's term for radio frequency handsets (analog and digital) that work on public mobile radio services, i.e., cellular telephone service.  Up until a couple of years ago, wireless handsets did not have to meet HAC or VC, primarily because this would have made the phones heavier/larger, and reduced battery life.  But digital cellular phones have become so important to the public that the FCC recently took steps to phase in HAC requirements on cell phones.
HOWEVER, please note that the FCC did NOT require VC support for cell phones!

* Private Radio Service -- this is a radio frequency handset that communicates only with a private PBX (privately owned phone system).
Examples of this include the SpectraLink brand of PBX radio handsets, and the Cisco 7920 WiFi phone.  As of this time, the FCC has made no move to require private radio service handsets be HAC or VC.  (Although Cisco voluntarily makes ours HAC.)
--------------

So, as we can see from the above info, no form of wireless phone is required to support VC at all.  Only "wireline" phones are required to do so.


For more information, see these FCC web pages:

FCC MODIFIES HAC EXEMPTION FOR DIGITAL WIRELESS TELEPHONES:
http://www.fcc.gov/cgb/consumerfacts/accessiblewireless.html: <http://www.fcc.gov/cgb/consumerfacts/accessiblewireless.html>


FREQUENTLY ASKED QUESTIONS REGARDING HEARING AID COMPATIBILITY AND VOLUME CONTROL (HAC/VC):
http://www.fcc.gov/Bureaus/Common_Carrier/FAQ/faq_hac.html: <http://www.fcc.gov/Bureaus/Common_Carrier/FAQ/faq_hac.html>


- John


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = : <mailto: = EMAIL ADDRESS REMOVED = > ] On Behalf Of Jim Tobias
Sent: Wednesday, November 15, 2006 12:32 PM
To: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] FW: TIA Request forGuidance(TEITACDiscussionsof 2006.11.13)


> -----Original Message-----
> From: John Combs (jcombs) [mailto: = EMAIL ADDRESS REMOVED = : <mailto: = EMAIL ADDRESS REMOVED = > ] > Sent: Wednesday, November 15, 2006 2:50 PM > To: = EMAIL ADDRESS REMOVED = ; TEITAC Telecommunications Subcommittee > Subject: Re: [teitac-telecom] FW: TIA Request for > Guidance(TEITACDiscussionsof 2006.11.13) > > Speaking from a manufacturer's standpoint, on our ITI-format Voluntary

> Product Accessibility Template (VPAT) for the 20 dB amplification > requirement, we state:
>
> "Supports when combined with compatible Assistive Technology"
>
> "Cisco IP Phones meets the FCC 68 requirements for volume gain of > minimum of 12dB of gain from default factor setting.
> To achieve 20dB or greater, Cisco recommends using an inline > amplifier, such as Walker Clarity CE-125, or Ameriphone Clarity HA-30.

> The Plantronics Clarity
> EC225/ECE225* inline amplifier is an example of a manufacturer selling

> 3rd party handset and headset amplifiers.  Recommended headset > amplifiers can be viewed through the following URL:
> http://www.plantronics.com/media/media_resources/literature/us: <http://www.plantronics.com/media/media_resources/literature/us>
> er_guides/
> cisco_setup.pdf
> "
>
> Most of our IP phones actually have 15 dB of gain, but for some reason

> no one wrote that into our VPAT!
>
> - John Combs

John -- has Cisco ever referred to the gain issue in VPATs for its wireless handsets?  (To be clear, Cisco makes wireless handsets not for public wireless networks but for its own VoIP phone systems.)

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